A prosecutor's closing address that invites the jury to speculate about why a complainant would put themselves through the ordeal of trial if not telling the truth is impermissible under Palmer v The Queen, but whether such comments cause a substantial miscarriage of justice depends on the adequacy of the trial judge's corrective directions, including directions on onus of proof, a Liberato direction, and specific directions not to speculate. Where an accused made a prior positive but false statement to authorities (not mere silence), the prosecutor may comment on the inconsistency between that statement and the defence raised at trial without infringing the Petty right of silence.
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